April 12, 2019

U.K. Subsea Oil-Services Firm Signs Two Sanctions Settlement Agreements

By Samuel Rubenfeld


The U.S. Treasury Department on Thursday announced two settlement agreements with Acteon Group Ltd. regarding violations of sanctions on Cuba and Iran.

The conduct in both cases concerned subsidiaries and affiliates of Acteon, a U.K.-based subsea services provider for the oil and gas industry, the Treasury said. The combined penalties were about $440,000; the companies self-disclosed the apparent violations, according to the Treasury.

Acteon is owned by investment funds affiliated with New York-based private-equity firm KKR & Co. Inc. KKR took a majority stake in Acteon in 2012, but the Treasury said the violations concerning Cuba pre-dated its ownership and that KKR doesn’t appear to have been involved in the violations regarding Iran.

In one case, Acteon subsidiary 2H Offshore Engineering Ltd. and its Malaysian affiliates provided engineering design analysis for oil well drilling projects in Cuban territorial waters, and sent engineers to Cuba to conduct workshops on the analysis, the Treasury said. In the other, three Acteon subsidiaries rented or sold equipment for projects in Cuban waters and sent engineers to service the equipment, and did the same for customers operating in Iranian waters.

The case concerning 2H Offshore centers on conduct between 2011 and 2012 by a former global director of the company, who found ways around company guidance prohibiting any business involving Cuba, according to the settlement document. The former global director minimized the Cuban nexus of the work by, among other things, submitting work proposals with the word “Cuba” omitted and directing administrative employees to remove the word “Cuba” from a post-trip expense report.

The 2H Offshore case was deemed “egregious” by the Treasury. Both Acteon and 2H Offshore committed to improving their corporate compliance programs, according to the settlement document signed by Acteon’s chief executive and 2H Offshore’s group general counsel.

In the other case, Treasury said Acteon subsidiaries Seatronics Ltd., Seatronics, Inc. and Seatronics Pte. Ltd. rented, sold or received a commission for referring shipments of equipment in Cuban waters on 10 occasions between August 2010 and March 2012, and sent engineers to service the equipment. Seatronics Ltd.’s Abu Dhabi branch rented or sold equipment in 2014 on three occasions to customers who appear to have embarked the equipment on vessels that operated in Iranian waters. The Treasury deemed the case as non-egregious.


Kharon research

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